NIOSH Comments on the SC&A Review of the Bethlehem Steel Site Profile Specific Responses to Findings, Observations and Procedural Non-conformances

To document more fully the applicability of the air monitoring data used in the site profile, NIOSH will add a section to the profile to address the quality, reliability and applicability of the early Atomic Energy Commission (AEC) air sampling program to the estimation of worker doses. Further, NIOSH will discuss how these measurements were consistent with the recommendations provided in ICRP 75, General Principles for the Radiation Protection of Workers. NIOSH recognizes that to appropriately determine exposure one must first critically evaluate the quality of the data. It is further recognized that air sample data may be collected for a variety of purposes and that any subsequent statistical analysis of such data must be viewed in the context of its original purpose. From the early days of operation, the Health and Safety Laboratory (HASL) of the Atomic Energy Commission (AEC) relied on time weighted average exposure measurements to assess inhalation hazards in the workplace. A brief description of the HASL methodology, and its relation to ICRP 75, is provided below.